Proposals are in place to build 14 lodges plus a 100-seat restaurant and leisure facilities on land at the old Treetop Stables, Feabuie, Culloden Moor.
The site sits north west of the visitor centre on the other side of Culloden Forest.
The land is included in the Culloden Battlefield Inventory, drawn up by Historic Environment Scotland to protect significant sites of conflict, and the Culloden Muir Conservation Area.
The application follows controversy over 16 new homes approved for land at nearby Viewhill Farm, which historians and campaigners claim is a war grave given the contact of Jacobite and Government forces in the area on April 16, 1746.
Campaigners are concerned the Viewhill development has set a precedent for further construction in the sensitive area.
George Kempik, of the Stop Culloden Development campaign, said: “It important that we stand up against this new development, which is a big test of the power of the new Culloden conservation area.
“It amazing that someone would come back with this plan given what we know about Viewhill Farm.”
Applicant Louise MacDonald, of Cawdor, near Inverness, said full reports had been completed on the Treetop site, including an archaeological assessment to locate any remnants from the battle.
She added: “We have done all the reports required, including and archaeological survey of the site which has come back clean.”
Ms MacDonald said she was aware of the controversy surrounding the Viewhill Farm development but wanted the new application to proceed through the planning process.
“It is the same with any planning application, you never quite know how it is going to turn out,” she added.
Viewhill Farm was given approval by a Scottish Government reporter in 2014 with an expanded Culloden Muir conservation area brought in by Highland Council the following year to better protect the sensitive land.
Plans for the holiday lodges were lodged with Highland Council last month.
A spokeswoman said the application was currently invalid given more information was required on the plans.
A Highland Council spokesperson said: “A planning application was received by Highland Council on 26 March. The application is currently invalid while additional information is sought from the applicant.
“The application site is located within both the designated Culloden Muir Conservation Area and the Culloden Inventory Battlefield.”
The National Trust for Scotland, which owns the core battlefield site and visitor centre, said it would lodge an objection to the application once it has been notified of the official application.
While the battlefield inventory aims to protect significant sites, it is not intended to prevent all development.
Highland Council will consider whether the proposed development will detract from the battlefield as well as it impact on the landscape, archaeology and what is know of the course of the battle.
A spokesman for Historic Environment Scotland said it will respond to the plans once consulted by the local authority.